Comprehension
The jurisdiction of this court has been invoked for protecting the Great Indian Bustard and the Lesser Florican, both of whom are on the verge of extinction. India faces a number of pressing near term challenges that directly impact the right to a healthy environment, particularly for vulnerable and indigenous communities including forest dwellers. The lack of reliable electricity supply for many citizens not only hinders economic development but also disproportionately affects communities, including women and low-income households, further perpetuating inequalities. Therefore, the right to a healthy environment encapsulates the principle that every individual has the entitlement to live in an environment that is clean, safe, and conducive to their well-being. The promotion of renewable energy sources plays a crucial role in promoting social equity by ensuring access to clean and affordable energy of all segments of society, especially in rural and undeserved areas. This contributes to poverty alleviation, enhances quality of life, and fosters inclusive growth and development across the nation. Therefore, transitioning to renewable energy is not just an environmental imperative but also a strategic investment in India’s future prosperity, resilience and sustainability. The right to equality under Art. 14 and the right to life under Art. 21 must be appreciated in the context of the decisions of this court, the actions and commitments of the state on national and international level, and scientific consensus on climate change and its adverse effects. By recognising the right to a healthy
environment, states are compelled to prioritise environmental protection and sustainable development, thereby addressing the root cause of climate change and safeguarding the well-being of present and future generations.
(Extract taken from MK Ranjitsinh and Ors v. Union of India, 2024 SC)
Question: 1

What is the objective of United Nations Framework Convention on Climate Change (UNFCCC)?

Updated On: Jan 13, 2026
  • To enforce international environmental treaties on climate change at national level
  • To stabilize greenhouse gas concentrations in the atmosphere to prevent dangerous human-induced interference with climate change
  • To stabilize carbon footprints and oversee global diversity protection efforts
  • All of the above
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The Correct Option is B

Solution and Explanation

The UNFCCC, or United Nations Framework Convention on Climate Change, is a major international agreement focused on global climate change. Its main goal is:

To stop the levels of greenhouse gases in the air from rising so much that they dangerously change the climate due to human activities.

The agreement creates rules to fight climate change by lowering greenhouse gas emissions and improving carbon sinks. It asks countries to work together and take action against climate change, based on the idea that everyone shares responsibility, but in different ways.

This goal is essential for protecting the Earth and keeping the environment balanced, supporting the right to a healthy environment as outlined in laws and international accords.

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Question: 2

Which of the following Sustainable Development Goals (SDGs) specifically addresses climate change?

Updated On: Jan 13, 2026
  • SDG 13
  • SDG 13
  • SDG 12
  • SDG 15
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The Correct Option is B

Solution and Explanation

The Sustainable Development Goals (SDGs) comprise 17 global objectives, interconnected and designed to guide the achievement of a better, sustainable future by 2030. Each goal tackles diverse global issues: poverty, inequality, climate change, environmental decline, peace, and justice.

Climate change presents a major global challenge, endangering natural and human systems. A specific SDG addresses this issue:

  • SDG 13: Climate Action - This goal focuses on immediate action to counter climate change and its consequences. It recognizes the growing climate threat and calls for collaborative efforts to alter societal practices and policies, minimizing adverse impacts.

By adhering to SDG 13, nations and communities pledge to boost climate resilience, promote renewable energy, decrease emissions, improve climate change education, and integrate climate considerations into policy and planning.

The extract emphasizes the significance of renewable energy in combating climate change and social inequities. It highlights the direct link between environmental protection, sustainable development, and human rights, such as the right to a healthy environment, vital for the prosperity and well-being of current and future generations.

In summary, SDG 13 specifically addresses climate change, underlining the need for global cooperation and action to solve this urgent environmental problem.

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Question: 3

In which of the following cases, the Supreme Court held that any disturbance of the basic environment elements namely air, water and soil, which are necessary for life, would be hazardous to ‘life’ within the meaning of Article 21 of the Constitution of India and Art. 48A and 51A(g) must be interpreted in the light of Article 21?

Updated On: Jan 13, 2026
  • M.C. Mehta v. Union of India, 2000 SC
  • M.C. Mehta v. Kamal Nath, 2000 SC
  • Vellore Citizens Welfare Forum v. Union of India, 1996 SC
  • M.C. Mehta v. Union Carbide Commission, 1991 SC
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The Correct Option is B

Solution and Explanation

The Supreme Court of India, in the case of M.C. Mehta v. Kamal Nath, 2000 SC, determined that harming essential environmental elements like air, water, and soil, vital for life, endangers 'life' as defined by Article 21 of the Constitution of India. Articles 48A and 51A(g) were also considered in relation to Article 21.
The court’s decision highlighted the fundamental right to a healthy environment as an integral part of the right to life under Article 21. This emphasizes the constitutional responsibility to protect environmental quality for present and future generations, requiring the state to prioritize the protection and sustainable use of natural resources.
This ruling supports the wider legal approach to India's environmental issues and confirms the judiciary's role in ensuring environmental protection as a key part of the right to life.
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Question: 4

Which of the following statements are correct?

Updated On: Jan 13, 2026
  • The people of India do not have a right against the adverse effects of climate change as pervious interpretations of Article 21 solely focussed on individual freedoms and right to clean and pollution free environment
  • Supreme Court for the first time recognized right to be free from adverse effects of climate change in its recent judgement MK Ranjitsinh and Ors v. Union of India, 2024 SC
  • There is no separate recognition given by the Supreme Court for ‘right to be free from adverse effects of climate change’ as it was already recognised under ‘right to a clean environment’
  • None of the Above
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The Correct Option is B

Solution and Explanation

In the 2024 Supreme Court case MK Ranjitsinh and Ors v. Union of India, the court for the first time recognized the right to be free from climate change's adverse effects. The Supreme Court acknowledged that a healthy environment includes freedom from climate change impacts. This decision relates to Article 21 of the Indian Constitution, which protects the right to life and liberty. The court highlighted environmental protection and sustainable development, connecting them to the well-being of present and future generations. This ruling is important for Indian environmental law because it broadens the right to a clean environment to include protection from climate change, making proactive climate action essential.
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Question: 5

Which of the following protocol focusses at limiting global temperature rise by reducing carbon emissions and combating climate change?

Updated On: Jan 13, 2026
  • The Montreal Protocol
  • The Kyoto Protocol
  • The Paris Agreement
  • The Rio Declaration
Show Solution

The Correct Option is C

Solution and Explanation

The Paris Agreement is a protocol addressing global warming by curbing carbon emissions and fighting climate change. Adopted in 2015 under the UNFCCC, it aims to fortify the global response to climate change, specifically to keep the global temperature increase this century under 2 degrees Celsius above pre-industrial levels, and to strive for a limit of 1.5 degrees Celsius.
Key goals of the Paris Agreement are:
  • Mitigation: Reducing greenhouse gas emissions.
  • Adaptation: Improving adaptation to climate impacts.
  • Financial Aid: Funding climate initiatives in developing nations.
The agreement uses a 5-year cycle where nations submit NDCs detailing their climate goals. It also fosters transparency and accountability via a system for monitoring progress and ensuring adherence.
Comparison of Protocols
Protocol/AgreementFocus
Montreal ProtocolProtecting the ozone layer by phasing out ozone-depleting substances.
Kyoto ProtocolLegally binding emission reduction targets for developed countries.
Paris AgreementLimiting global temperature rise and reducing carbon emissions worldwide.
Rio DeclarationBroad principles for sustainable development and environmental protection.
Therefore, the correct answer is: The Paris Agreement.
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Top Questions on Environmental Law

Questions Asked in CLAT PG exam

An unpleasant tussle ensured between the TATA Sons and Cyrus Pallonji Mistry (“CPM”) in October 2016, when Mistry, who was the sixth chairman of Tata Sons, was ousted from the position of Executive Chairman of Tata Sons Limited. CPM took over as the chairman in 2012 after Ratan Tata announced his retirement. Tata Group patriarch Ratan Tata had personally asked Cyrus Mistry to resign as chairman of Tata Sons as the board had lost faith in him, but his refusal led to the removal via majority vote. Cyrus Investments Private limited and Sterling Investment Corporation Private Limited belonged to the Shapoorji Palloni Group in which CPM held a controlling interest (about 2% of the issued share capital of Tata Sons). Seven out of the nine directors of Tata Sons voted for CPM’s replacement after Farida Khambata abstained and Mistry was declared ineligible to vote as he was an interested director. Mistry challenged his removal, accusing the board of mismanagement and of oppressing minority shareholders. however, the National Company Law Tribunal (NCLT) rejected his petition. After this Mistry challenged his removal in National Company Law Appellate Tribunal (NCLAT). In 2018, NCLAT order restored Mistry as the group’s executive chairman. Tata Sons challenged that NCLAT order in Supreme Court. CPM also challenged the order for few more relief. Supreme Court stayed NCLAT’s order reinstating Cyrus Mistry as the executive chairman of Tata Sons and restoring his directorships in the holding company as well as three group companies, with a preliminary observation that the first impression of the order was “not good” and that the tribunal ‘could’ not have given consequential relief that had not been sought in the first place. Ultimately, the Supreme Court decided the case in favour of Tata Sons. One of the issues decided by Supreme Court was that “whether the case was fit to be qualified as a situation of ‘Oppression and Mismanagement’ under Section 241 of the Companies Act, 2013?”. On this issue, the Supreme Court observed that “unless the removal of a person as a chairman of a company is oppressive or mismanaged or done in a prejudicial manner damaging the interests of the company, its members or the public at large, the NCLT cannot interfere with the removal of a person as a Chairman of a Company in a petition under Section 241 of the Companies Act, 2013.” This case highlighted the point that “an executive chairman does not have sovereign authority over the company. In corporate democracy, decision making always remains with the Board as long as they enjoy the pleasure of the shareholders. Likewise, an executive chairman will continue as long as he/she enjoys the pleasure of the Board. An assumption by the executive chairman that he/she would have a free hand in running the affairs of the company is incongruous to corporate governance and corporate democracy. The Tribunal held that the concept of ‘free hand rule’ is antithesis to collective responsibility and collective decision making”.
[Based on Tata Consultancy Services Ltd. v. Cyrus Investment Pvt. Ltd., 2021 SCC 122].
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Alastair Hudson in his book ‘Securities Law’ First Edition (Sweet & Maxwell), 2008 at page 342, refers to ‘Restricted Offers’ and noticed that there is no contravention of Section 85 of FSMA 2000, if: “(b) the offer is made to or directed at fewer than 100 persons, other than qualified investors, per EEA State”. The purpose underlying that exemption, the author says, is mainly the fact that the offer is not being made to an appreciable section of “the public” such that the policy of the prospectus rules generally is not affected. Further, the author says that “Self-evidently, while an offer to 99 ordinary members of the public would be within the literal terms of the exemption, it would not be the sort of activity anticipated by the legislation. Moreover, if a marketing campaign were arranged such that ordinary members of the people were approached in groups of 99 people at a time in an effort to avoid the prospectus rules, then that would not appear to be within the spirit of the regulations and might be held to contravene the core principle that a regulated person must act with integrity.”
I may, therefore, indicate, subject to what has been stated above, in India that any share or debenture issue beyond forty-nine persons, would be a public issue attracting all the relevant provisions of the SEBI Act, regulations framed thereunder, the Companies Act, pertaining to the public issue. Facts clearly reveal that Saharas have issued securities to the public more than the threshold limit statutorily fixed under the first proviso to Section 67(3) and hence violated the listing provisions which may attract civil and criminal liabilities. Principles of listing, which I may later on discuss, is intended to assist public companies in identifying their obligations and responsibilities, which are continuing in nature, transparent in content and call for high degree of integrity. Obligations are imposed on the issuer on an ongoing basis. Public companies who are legally obliged to list their securities are deemed to accept the continuing obligations, by virtue of their application, prospectus and the subsequent maintenance of listing on a recognized stock exchange. Disclosure is the rule, there is no exception. Misleading public is a serious crime, which may attract civil and criminal liability. Listing of securities depends not upon one’s volition, but on statutory mandate.
[Extract from Sahara India Real Estate Corporation Limited v. Securities and Exchange Board of India (SEBI), Para 89-91, Civil Appeal No. 9833/2011 (SC)]
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The aim of the rules of natural justice is to secure justice or to put it negatively to prevent miscarriage of justice. These rules can operate only in areas not covered by any law validly made. In other words, they do not supplant the law of the land but supplement it. The concept of natural justice has undergone a great deal of change in recent years. In the past, it was thought that it included just two rules namely: (1) no one shall be a judge in his own case (Nemo debet esse judex propria causa) and (2) no decision shall be given against a party without affording him a reasonable hearing (audi alteram partem).
Very soon thereafter a third rule was envisaged and that is that quasi-judicial enquiries must be held in good faith, without bias and not arbitrarily or unreasonably. But in the course of years many more subsidiary rules came to be added to the rules of natural justice. Till very recently it was the opinion of the courts that unless the authority concerned was required by the law under which it functioned to act judicially there was no room for the application of the rules of natural justice. The validity of that limitation is not questioned.
If the purpose of the rules of natural justice is to prevent miscarriage of justice one fails to see why those rules should be made inapplicable to administrative enquiries. Often times it is not easy to draw the line that demarcates administrative enquiries from quasi-judicial enquiries. Enquiries which were considered administrative at one time are now being considered as quasi-judicial in character. Arriving at a just decision is the aim of both quasi-judicial enquiries as well as administrative enquiries. An unjust decision in an administrative enquiry may have more far reaching effect than a decision in a quasi-judicial enquiry as observed by this Court in Suresh Koshy George v. University of Kerala [Civil Appeal No. 990/68, decided on 15-07- 1968], the rules of natural justice are not embodied rules. What particular rule of natural justice should apply to a given case must depend to a great extent on the facts and circumstances of that case, the framework of the law under which the enquiry is held and the constitution of the Tribunal or body of persons appointed for that purpose. Whenever a complaint is made before a court that some principle of natural justice had been contravened the court has to decide whether the observance of that rule was necessary for a just decision on the facts of that case.
[Extract from the judgment of the Supreme Court in A.K. Kraipak v. Union of India, (1969) 2 SCC 262, decided on April 29, 1969, hereafter ‘A.K. Kraipak’].
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The doctrine of promissory estoppel is by now well recognized and well defined by a catena of decisions of this Court. Where the Government makes a promise knowing or intending that it would be acted on by the promise and, in fact, the promise, acting in reliance on it, alters his position, the Government would be held bound by the promise and the promise would be enforceable against the Government at the instance of the promise notwithstanding that there is no consideration for the promise and the promise is not recorded in the form of a formal contract as required by Article 229 of the Constitution. The rule of promissory estoppel being an equitable doctrine has to be moulded to suit the particular situation. It is not a hard-and-fast rule but an elastic one, the objective of which is to do justice between the parties and to extend an equitable treatment to them. This doctrine is a principle evolved by equity, to avoid injustice and though commonly named promissory estoppel, it is neither in the realm of contract nor in the realm of estoppel. For application of the doctrine of promissory estoppel the promise must establish that he suffered in detriment or altered his position by reliance on the promise.
Normally, the doctrine of promissory estoppel is being applied against the Government and defence based on executive necessity would not be accepted by the court. However, if it can be shown by the Government that having regard to the facts as they have subsequently transpired, it would be inequitable to hold the Government to the promise made by it, the court would not raise an equity in favour of the promise and enforce the promise against the Government. Where public interest warrants, the principles of promissory estoppel cannot be invoked. The Government can change the policy in public interest. However, it is well settled that taking cue from this doctrine, the authority cannot be compelled to do something which is not allowed by law or prohibited by law. There is no promissory estoppel against the settled proposition of law. Doctrine of promissory estoppel cannot be invoked for enforcement of a promise made contrary to law, because none can be compelled to act against the statute. Thus, the Government or public authority cannot be compelled to make a provision which is contrary to law.
[Extract from the judgment of the Supreme Court in Shree Sidhbali Steels Limited v. State of Uttar Pradesh, (2011) 3 SCC 193, decided on January 20, 2011, hereafter ‘Shree Sidhbali Steels’].
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